October 29, 2010
This is a follow up to my 10/22/10 comment. I am extremely disappointed that the Sec has not even discussed or addressed 12b1 fees in wrap fee accounts in this proposal.If you believe a 12b1 fee is a form of commission then this type of fee either should be rebated to the client or eliminated in fee based accounts. There should be agreement at the sec that wrap fee accounts are sold to clients as commision free. If a 12b1 fee is a commission then the client is being misled. I would appreciate the opportunity to dicuss my views on this issue with a member of the sec staff. I can be reached at 410-715-3600.